IBM has filed a Reply to SCO's Response to Motions to Convert the Debtors' Chapter 11 Cases [PDF], just as Novell did earlier today. Here's the SCO Response IBM here replies to, and here's the original IBM Motion SCO is opposing. IBM's Introduction section will give you the flavor in the very first sentence:

In response to the Motions to Convert, the Debtors argue (a) even though they continue to bleed cash, lose customers and shrink merely to survive and the only chance of rehabilitation is success on the appeal in their nonbankruptcy litigation (the "Utah litigation") they should be given as long as it takes for the Utah litigation to be resolved; (b) they really are not losing all that much money and besides, they have lost money every year that they have been in business; (c) their customers really need them to survive, even at the expense of all the creditors of the estate, because the creditors are not actively complaining about the losses; and (d) a Chapter 7 trustee will likely squander the opportunity to recover billions of dollars in potential damages from IBM and Novell, among others.

Here's the first header: "The Debtors Should Not Be Allowed to Remain in Chapter 11 Indefinitely Just to Pursue Litigation." How many times have we heard SCO represent to the bankruptcy court that all they need is just one more step in the Utah litigation to rehabilitate, IBM asks?
Oooh, ooh. [hand waves in the air] I know, I know! More than we've enjoyed?
We're working on the complete text for you, and we'll post it here as soon as we can. But how do you like the descriptive phrase, that SCO is shrinking to survive?

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